We at StringTM Ltd (“StringTM”) respect your privacy. This policy sets out our practices and approach to respectful handling of your personal information.

In order to serve you better, understand your needs and communicate with you, StringTM collects, exports and uses some of your information. For example, when you order products or services, request information, subscribe to marketing, enter competitions or participate in surveys we may ask you to provide personal information to complete these transactions. The types of personal information we collect about you may include contact information such as your name, address, telephone number, and email address; and other unique information.

If you have any questions about this policy or wish to access your personal information, please feel free to contact us via support@stringtm.com.

1. Information We Collect

Personal Information (PI) is any information about an individual from which their identity can reasonably be ascertained. You, or someone acting on your behalf, may provide PI to us when you interact with us online and off line.
For example:

• We may gather such information as name, physical address, email address and phone number when you contact or communicate with us.
• We may gather information about your use of our products and services, and your other dealings with us, including any contact we have with you by telephone, email or online. This information may include your pick-up and destination addresses for Total Mobilty journeys, your device and vehicle location.
• We may gather user preferences, product/service interests and other customer profile information when you register with us, subscribe to a newsletter, participate in an event, program or promotion, use our app or click on a URL.
• We may also collect information about your vehicle, qualifications, experience, company and feedback from passengers.
• We may also collect PI from third parties including public sources, our related companies, your organisation, information service providers, social media and the parties with whom we exchange information as described in this policy.

Please also see section 4 of this policy, which provides details regarding the automated collection of certain data, some of which may be considered PI.
Where you provide us with PI about someone else you must have their consent to provide their PI to us based on this policy.

2. How We Use Personal Information

The information StringTM collects to understand your needs and interests helps us deliver a consistent and personalised experience. StringTM may use your PI to:

• assist you in completing a Total Mobility trip.
• provide service and support.
• protect the safety and security of our customers, staff and members of the public
• prevent and detect fraud, abuse, breaches of our terms and other malicious activity
• process, fulfil and follow up on transactions and requests for products, services, support, training and information
• create and maintain an account for you
• communicate with you about products and services (including for marketing and advertising purposes)
• maintain and update our records
• conduct product and market research
• train and manage our people
• improve and adapt our website, apps and services to meet your needs and the needs of our customers generally
• allow you to participate in contests and surveys

We may not be able to do these things without your PI. For example, we may not be able to communicate with you or provide our services.

We may also use your PI for other purposes to which you have consented, to protect our lawful interests and the rights of others, or where we authorised or required by law.

3. How We Share Personal Information

StringTM will only disclose your PI to third parties as contemplated by this privacy statement, or as otherwise authorised or required by law.

StringTM retains service providers and suppliers to assist us to deliver products, services and customer solutions and with marketing and other communication initiatives.

We may exchange PI with these providers and suppliers which include, for example, Council Ridewise platforms, providers of customer support, email service providers, automated data processors, technology providers, security and monitoring providers and shipping agents.

We may also exchange PI with third parties as follows:

• with our related companies, for example to support business and marketing processes.
• to taxi companies who provide transportation services who engage you as a driver or provide transportation services to you.
• to government authorities, investigators and legal advisors as appropriate, if required by law or we suspect a violation of our policies or to protect the rights or safety of any person or entity.
• in the event of a complaint, dispute or conflict between Operator or a Driver and a User, to the other party to the dispute.
• based on a good-faith belief that disclosure is necessary to respond to judicial process, valid government inquiry, or as otherwise required or authorised by law.
• in the event that StringTM or any of its assets are or may be acquired (e.g. your PI may be transferred with the company or the asset).
• with partners in any co-branded service or promotion in which you participate.
• with your travel companions where you choose to travel with other passengers.
• to third parties in connection with your sharing of information (e.g., when you post an update to a social network).
• to other third-parties for purposes you have allowed; or
• to other third parties with your consent.

The PI that we collect may be transferred to, and stored in, Australia, UK, EU, New Zealand, USA, Canada and other countries.

4. Online Services

We may interact with you through a range of online services such as our website stringtm.com, social media profiles, email and our mobile apps (e.g. StringTM Trip Manager).

If you install or access our online services for any purpose, our system may record information such as your IP address, device details (including location and identifiers of your device), top level domain (e.g. .com, .au, etc), date and time of your interaction with our online services or of our collection of information, pages accessed, information downloaded, previous site visited and browser type. This information is used to administer and provide our online services (e.g. to ensure compatibility of apps with your device), for statistical, reporting and maintenance purposes, and for the other purposes described in this policy.

Like many other websites, our website may use ‘cookies’ from time to time. A cookie is a piece of information that allows our system to identify and interact more effectively with your browser. Some of the cookies help us to maintain the continuity of your browsing session and remember your details and preferences when you return. Others may be used for advertising or analytics, as described below, or for other purposes described in this policy. Other technologies that may be used include web beacons (which may operate in conjunction with cookies), Flash cookies and JavaScript.

You can configure your web browser software to reject certain cookies and block JavaScript however some parts of our online services may not have full functionality in that case. You can control your preferences regarding Flash cookies at http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html. You can use your browser and/or device settings to control whether and when your device location is shared.

When we send you emails or other electronic messages, we may record where you open the message and click on particular links. This helps us to better understand what information is of interest to you.

Some of our online services give you the ability to choose to make your own content (such as feedback and comments on our services) publicly accessible. Where any information preference is set to ‘public’ then users should be aware that it may be viewed by other users of the online services, and may be stored any disseminated on an ongoing basis by third parties such as search engines, even after you remove the content or set it to “private”. We may use your public content and feedback on our services for promotional purposes or any other purpose.

We may participate in third party ‘online behavioural advertising’ (OBA), on a non-personally identifiable basis. This allows online advertising displayed to you to be tailored according to your browsing behaviour on various websites and apps, not just our own. You can find you more details about OBA, the best practice guidelines and how to opt out from OBA with participating companies at the industry website www.youronlinechoices.com.au.

In many cases, we do not associate information collected in relation to use of our online services with other PI. Where we do, we treat the online information as PI and handle it in accordance with this privacy policy.

Third parties may collect PI about your online activities over time and across different websites when you use our online services. In some cases, we may arrange for a third party to collect PI or other information directly from you on our website or other online services, such as through embedded content, embedded videos, embedded social network buttons or automated advertising technology. Some of these third parties may combine the information they collect with other information that they have collected from you across other websites and online services, including PI. All such third-party providers’ handling of the information is subject to their own privacy policies, terms and practices and is not covered by this policy.

Our online services use certain Google services such as Google Places API for iOS and Android and we may use Google Analytics from time to time. For more about how Google collects and processes data, please see Google’s privacy policy and their information at https://www.google.com/policies/privacy/.

5. Your Choice

StringTM will send you a variety of information that complements our products and services. This will include certain product- and service-specific information and also StringTM general communications. We deliver StringTM general communications by email and telephone (SMS).

You can make or change your choices about receiving either subscription or general communications at the data collection point or by using other methods, which are listed in the following sections. This option does not apply to communications primarily for the purpose of administering order completion, contracts, support, product safety warnings, driver updates, or other administrative and transactional notices as the primary purpose of these communications is not promotional in nature.

Subscription communications include email newsletters, product updates, etc. that may be expressly requested by you or which you consented to receive. After you request such communications, you may opt out of receiving them by using one of the following methods:

• Select the email or SMS "opt out" or "unsubscribe" link, or follow the opt-out instructions included in each subscription communication.
• Contact the StringTM privacy officer, as set out below. Be sure to provide your name, email and postal address, and specific relevant information about the StringTM subscriptions that you no longer wish to receive.

You may contact us as described in the “Contacting us” section below to request removal of content or information on our website or online services that you have posted there in a location viewable by other users (for example, a public comment on our blog). Depending on the law of your jurisdiction, this removal may not ensure complete or comprehensive removal of the content or information you posted. For example, it generally will not remove content or information that has been stored, shared or re-posted by other users and other third parties.

6. Keeping Your Information Secure

To reduce the risk of unauthorised access or disclosure and the inappropriate use of your PI, StringTM employs various physical, technical and administrative procedures to safeguard the PI we hold. We hold PI electronically and in hard copy form, both at our own premises and with the assistance of our service providers.

7. Accessing and Updating Your Information

Please contact us as set out below if you have any queries or concerns about privacy or wish to access or correct any PI we may hold about you. We may need to verify your identity.

In the case of access and correction requests, please provide as much detail as you can about the particular PI you seek, in order to help us locate it. We will provide our reasons if we deny any request for access to or correction of PI. Where we decide not to make a requested correction to your PI and you disagree, you may ask us to make a note of your requested correction with the PI.

8. Contacting Us

We value your opinions. If you have comments or questions about our privacy policy, please send them to the StringTM Privacy Officer at:

Email: support@stringtm.com

If you have any concerns that we have interfered with your privacy, please write to us. We may request additional details from you regarding your concerns, and may need to engage or consult with other parties in order to investigate and deal with your issue. We will keep records of your request and any resolution.

StringTM Ltd
Last updated: 30 September 2018